1.

You mentioned that you used to be the head of the Branch Expansion unit of PSBank
correct?

2. And as the head of the Branch expansion unit, you are the one who scouts for possible
new branches or relocation sites, correct?

3. And once you have identified the possible relocation site, you are also the one who
coordinates and or negotiates with the owners of those intended relocation site, correct?

4. How long have you been the Branch Expansion unit head of the Bank?

5. Now how many branches have been set up or established by you as the Branch
Expansion Unit head of the Bank?

6. And in those expansions or relocations, are the sites occupied by the branches, owned or
leased by the Bank?

7. So in other words, there have been several instances already that you have negotiated for
branch relocation or establishment whereby you merely leased the area where the branch will
be established, correct?

4. Now, as regards branch relocations, such as when, it intends to lease a portion of building
for its relocation site, the Bank has certain basic requirements from the future lessor before it
proceeds with the lease, correct?

5. And among those documents you require the future lessor to provide to you, as in the
present case, are copies of the building permit and occupancy permit of the building, correct?

6. And according to you, (Q&A 15) the submission of those documents to the Bank is very
important because they are required by the Building Official of Quezon City in order to apply
for the Bank’s own building/renovation permit and occupancy permit for the space it intends to
lease and renovate for putting up its branch, correct?

7. Now in this case, before PSBank executed the contract of lease with Hokkwell, you
mentioned in your judicial affidavit (Q&A 15 to 21) that you asked Hokkwell or Mr. Lim to
submit to you the building permit and occupancy permits of the building where Psbank
intended to relocate its branch, correct?

8. But according to you, as early as January 29, 2015, Hokkwell or Mr. Richard Lim already
informed you that due to the age of the building, the Quezon City Government no longer has
a copy of the building permit nor the occupancy permit, correct?

9. In other words, as early as January 29, 2015, you or PSBank had already been informed
by the defendant that the building permit and occupancy permit of the building were no longer
available, correct?

10. But despite the fact that those documents were no longer available, PSBank still
proceeded with the lease, correct?
11. Now, you said in Q & A No. 15 that the submission of said permits is necessary, correct?
12. In other words, these permits are crucial because according to you, before the
Department of Building Official can grant PSBank its own building/renovation permit and
occupancy permit for the leased units, it needs first the building permit and occupancy permit
of the building of Hokkwell itself, correct?

13. But, despite knowing that these documents are crucial, you or PSBank still proceeded
with the lease even without said documents, correct?

14. And despite knowing that the submission of said permits are crucial for purposes of the
intended relocation of the branch, the submission of said documents to PSBank were not
listed in January 13, 2015 letter of PSBank to Hokkwell, containing the basic terms and
conditions of the lease, correct?

15. And the submission of the building and occupancy permit of the building was also not
listed as Hokkwell’s deliverables to the Bank under the lease contract dated March 6, 2015,
correct?

16. In Q25 of your judicial affidavit, according to you, in his email to you on January 30, 2015,
PSBank’s Architect Conde stressed that the Department Official requires the occupancy
permit of the building owner for the application of the occupancy of the tenants, correct?

17. But again, despite such emphasis made by PSBank’s Architect Conde on the importance
of the submission of the building’s occupancy permit, still the PSBank executed the lease
contract with the defendant knowing that the occupancy permit is not available, correct?

=============
(Assist Q&A No. 26)

18. In Q 26 of your judicial affidavit, you mentioned that Mr. Lim promised to assist PSBank in
the application for building/renovation permit and occupancy permit if the building certification
will not notice, now did Mr. Lim or Hokkwell indeed extend assistance to PSBank? Yes.

19. In fact, he even offered Hokkwell’s contractor who was willing to assist PSBank in the
processing of its renovation permits as said contractor has already a contact person who
facilitates documentary requirements, correct?

20. But PSBank never got in touch with Hokkwell’s contractor, correct?

21. So, Hokkwell has been very cooperative and accommodating with PSBank, correct?

22. In fact, upon PSBank’s request, for purposes of facilitating PSBank’s occupancy permit,
Hokkwell has readily caused the conduct of a building audit of the building correct?

23. And Hokkwell caused the conduct of a building audit despite the fact that the same was
not included in the terms of the lease contract, correct?
24. Hokkwell engaged the services of several professionals just so it could comply
accommodate PSBank’s requests, correct?

25. And because of the engagement of said professionals, Hokkwell was able to submit the
structural certification, electrical certification, sanitary and plumbing certification and
mechanical certification to PSBank correct?

26. Now, did Hokkwell charge PSBank for the services of the said professionals?

27. In Q&A No. 41 of your judicial affidavit you mentioned that, “Hokkwell submitted the
electrical, sanitary and plumbing, mechanical and structural certifications. However, after
these certifications were presented, the Department of Building Official required additional
documents from Hokkwell such as the Structural Plan and Material Test Result.

28. Now, are you aware what these structural plans and material test result are?

–- If yes, when did you come to know about these documents? - if only now, so, in other
words, these documents were not even contemplated upon by the parties when it entered into
the lease contract, correct?
- Can you please show to us where specifically it is indicated in the lease contract?

** if before – you knew already these documents, yet you never included them in the
terms of the lease contract as deliverables by the defendant?

29. In other words, these documents were not among those contemplated upon by the
parties when the entered into the lease contract, correct?

Hokkwell was made to submit again documents were not listed in the terms of the lease,
correct?

Now is it not that the Hokkwell Is not that the Hokkwell caused the And Hokkwell has been
cooperative and accommodating to PSBank in fact, it even caused the conduct of a building
audit, and engaged and paid for the services of the several professionals just despite the

e submission of said d despite knowing that despite the fact that the
a copy of the occupancy permit of the building, correct?
9. As regards the building permit, you also mentioned that Mr. Richard Lim also informed you
that
which was built in 1963, he does not have a copy of the building permit and the occupancy
permit of the building
you are the s a the head of the Branch expansion unit, you are also aware of the basic
documentary requirements Being the head of the Branch expansion unit, you are also aware
of the necessary requirements of the necessary requirements that need to be complied with
by the e